PART I - GENERAL STANDARD DISCLOSURES

Gonvarri Corporación Financiera, S.L. (henceforth Gonvarri or GSS) was founded in 1958, conducting business in manufacturing, processing and trading in steel products and metals related to the iron and steel industry.

The corporate structure of the Gonvarri Corporacion Financiera is 100% owned by HOLDING GONVARRI S.R.L.

Headquarters are in:

Prolongación de Embajadores, s/n.

28053 Madrid – Spain

Our products can be grouped into 3 business lines: Au­tomotive, Industry and Metal Structures, which includes the lines of Road Steel, Solar Structures, Almaceno (Logístics) and Mecano, among others.

Governance, Ethics, Anticorruption and Compliance

In 2016 a project focused on developing the new ¨Compliance Model¨ was initiated through the Internal Audit area. Within this project a deep revision of the Code of Ethics and Conduct was done, just as the revision of various anti-corruption, risk, commercial sanctions and information exchange policies, among others, which were all approved by the Board of Directors in September 2017 and January 2018.

These policies will be outlined hereunder:

・ Code of Ethics and Conduct

・ The statute of the Compliance Committee

・ Compliance Policy

・ Rule zero

・ Anti-fraud and corruption Policy

・ Compliance Model supervision plan

・ Functions and responsibilities of Internal Audit department and compliance

・ Rules of procedure of the Ethics Channel

・ Corporate policy on trade sanctions

・ Corporate policy for tax risk management

・ Corporate policy for risk control and management

・ Corporate policy for information exchange with the competition

Our Management Model “Drive”

Drive is the Management Model that pushes Gonvarri to reach its profitability and growth objectives. The model is based on people, on the efficiency of the continuous improvement of its processes, on the particular effort in innovation, and always with a focus on sustainability.

Our contribution to the SDG

From our commitment to sustainability, we, at Gonvarri Steel Services, are aware of the importance of an active participation to contribute to the success of these. For this reason, we have defined 4 direct objectives which are linked to our management model and our future strategy, just as other indirect objectives, which are outlined next:

Relevant aspects: materiality analysis

Several aspects were identified. This allowed us to group the relevant information in 21 aspects. Next, we weighed these 21 aspects, from an internal and external perspective, to identify the most relevant to our stakeholders and to the company.

After this analysis, consideration and revision, a total of 11 global material subjects were defined.

・ Presence in new countries and new product development.

・ The commitment of senior management to sustainability and governance.

・ Formal ethical and anti-corruption framework. Communication, implementation and Complaint channels.

・ Formal risk control and compliance framework. Communication, implementation and complaint channels.

・ Policies related to Human Rights, Complaint and response channels.

・ Talent attraction and retention. Training, professional development and performance assessment programs.

・ Social action and local community dialogue programs and strategy.

・ Security and health management for employees and outsourced contracts.

・ Environmental management.

・ Energy: Consumption, plans, and energy efficiency programs and development of renewable energies.

・ Innovation: products, quality, security, environmental impact and process efficiency.

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